Played around with this earlier today with the ECE typschlussel, 41FF for LCI M340iX sedan according to ISTA+. You are right - the cafd is the same between both FLM modules and there does not appear to be any difference in the coding between them.
Coding the FLM modules with ECE type triggers lowbeam errors
unlike pre-LCI.
As mentioned earlier using the Staging data from the original post makes both lights do the flashing animation concurrently rather than 'sweeping' from side to side. The goodbye/lock animation doesn't change from the US version btw, not sure if this is correct or if there is another line that needs to be changed.
The amber sidemarkers flicker during the animation as well. I guess it would be better if I can figure out how to turn them off. Based on the coding it looks like it might be LM01 or LM11?
I've attached the ncd compare, maybe you can make better sense of it than me. NCD1 is coding based on US FA (with 5AP deleted), NCD2 is ECE.